Completion certificate delay by local authority cannot deny housing project deduction on timely compliance and completed project.

Deduction under section 80IB(10) should not be denied merely because the completion certificate was issued after the statutory cut-off when the housing project was completed before that date, the assessee had applied for certification within time, and all required formalities were complied with. Delay caused by the local authority's inspection process, rather than any default by the assessee, cannot defeat the claim where no defect or material shows non-completion before the cut-off. The provision's object of promoting housing projects requires a practical construction, so the deduction remains available on substantial compliance.

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Issues: Whether deduction under section 80IB(10) could be denied merely because the completion certificate from the local authority was issued after 31.03.2008, despite the assessee having applied within time and substantially complied with the statutory requirements.

Analysis: The projects were found to have been completed before the statutory cut-off, and the assessee had applied for completion certificates on 26.11.2007 with all required formalities complied with. The local authority did not point out any defect or irregularity in the application, and the delay in issuing the certificates was attributable to the authority's inspection process rather than any default by the assessee. The legislative object of section 80IB(10) is to promote housing projects, and the requirement of completion certificate cannot be applied so rigidly as to penalize an assessee for a delay beyond its control, especially where the authority later issued the certificates and no adverse material showed non-completion before the cut-off date.

Conclusion: Deduction under section 80IB(10) was rightly allowed, and the revenue's challenge failed.

Ratio Decidendi: Where an assessee completes the housing project, applies for the completion certificate within time, and the delay in issuance is attributable to the local authority, deduction under section 80IB(10) cannot be denied solely on the ground that the certificate was issued after the statutory date.

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